Cruz vs. CA -G.R. No. 123340.

August 29, 2002

Facts: Lutgarda Cruz was charged with the crime of “Estafa through Falsification of Public Document” before
the Manila Regional Trial Court. Petitioner executed before a Notary Public in the City of Manila an Affidavit
of Self-Adjudication of a parcel of land stating that she was the sole surviving heir of the registered owner when
in fact she knew there were other surviving heirs. Since the offended party did not reserve the right file a separate
civil action arising from the criminal offense, the civil action was deemed instituted in the criminal case. On
January 28, 1994, petitioner received a copy of the decision. On February 10, 1994, petitioner filed by registered
mail a motion for reconsideration dated February 7, 1994, assailing the trial court’s ruling on the civil aspect of
the criminal case. Petitioner furnished the City Prosecutor a copy of the motion by registered mail. Left with no
recourse, petitioner filed a petition for certiorari and mandamus with the Court of Appeals to nullify the two
assailed orders of the trial court. Petitioner also asked the Court of Appeals to compel the trial court to resolve
her motion for reconsideration of the decision dated February 7, 1994.

After trial on the merits, the trial court rendered its decision dated January 17, 1994acquitting petitioner on the
ground of reasonable doubt. In the same decision, the trial court rendered judgment on the civil aspect of the
case, ordering the return to the surviving heirs of the parcel of land located in Bulacan.

Issue: Whether or not the RTC of Manila had jurisdiction over the civil aspect of the case?

Held: Yes. The RTC of Manila has jurisdiction to render judgment on the civil aspect of the Criminal Case.
There are three important requisites which must be present before court can acquire criminal jurisdiction. First,
the court must have jurisdiction over the subject matter. Second, the court must have jurisdiction over the territory
where the offense was committed. Third, the court must have jurisdiction over the person of the accused.

In the instant case, the trial court had jurisdiction over the subject matter as the law has conferred on the court the
power to hear and decide cases involving estafa through falsification of a public document. The trial court also
had jurisdiction over the offense charged since the crime was committed within its territorial jurisdiction. The
trial court also acquired jurisdiction over the person of accused-petitioner because she voluntarily submitted to
the court’s authority. Where the court has jurisdiction over the subject matter and over the person of the accused,
and the crime was committed within its territorial jurisdiction, the court necessarily exercises jurisdiction over all
issues that the law requires the court to resolve. One of the issues in a criminal case is the civil liability of the
accused arising from the crime. Article 100 of the Revised Penal Code provides that “[E]very person criminally
liable for a felony is also civilly liable.” Article 104 of the same Code states that “civil liability x x x includes
restitution.”